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EAA: Key Dates, Penalties, and Compliance

The European Accessibility Act (EAA) mandates accessibility in EU products and services; this article outlines key dates, penalties, and the compliance impact. With the deadline approaching, organizations must react to the EAA’s requirements, deadlines, and potential impact on operations. This blog examines who the EAA applies to, what products and services are covered, and practical steps for businesses to achieve compliance with these critical regulations with a focus on digital documents.

What is the European Accessibility Act (EAA)?

The European Accessibility Act (EAA) unifies accessibility standards to create consistent accessibility expectations across EU member states. Its goal is equal access for individuals with disabilities. Introduced in 2019, the directive builds on prior regulations, such as the European Web Accessibility Directive, and specifies accessibility requirements for businesses, especially those offering digital products and services.

Key Objectives of the EAA:

  • Remove market barriers by harmonizing accessibility laws across the EU.
  • Improve access to products and services for all people including those with disabilities.
  • Encourage innovation and create a more inclusive digital environment.

By mandating compliance with the EAA, the EU hopes to create a more inclusive digital marketplace, removing unnecessary accessibility barriers for individuals with disabilities.

EAA: Key Dates for Compliance

One of the most important aspects of the EAA is its phased implementation timeline. Businesses must be aware of two key deadlines:

  1. 28 June 2025: From this date, new products and services that fall within the scope of the EAA must comply with the accessibility requirements outlined by the local legislation of the EU member states.
  2. 28 June 2030: This date marks the deadline by which all in-scope products and services—whether newly launched or existing—must be compliant with local accessibility standards, regardless of their original release date. Services must stop using inaccessible products that were in use before June 28, 2025. Additionally, Member States will start reporting on the Act’s impact and implementation.

Companies operating within the EU should begin assessing their products and services now to ensure they are prepared for these deadlines. Failing to meet the 2025 and 2030 deadlines could result in penalties, which will vary depending on each member state’s enforcement policies.

Sectors Affected by the EAA:

  • Electronic communication services: This includes most online messaging platforms and services that allow users to access audiovisual content.
  • Banking and financial services: Consumer-facing digital banking services and payment terminals must adhere to the accessibility standards.
  • Transportation services: Ticketing machines, travel apps, and online booking systems will need to meet EAA compliance.
  • E-commerce: Retail websites and online services must comply with accessibility requirements, though the products sold on these platforms may not necessarily fall under the act.

Importantly, businesses outside of the EU that provide services to EU citizens must also comply with the EAA. For example, a U.S.-based company offering a mobile app to EU users would need to ensure its app meets the EAA’s accessibility standards​​​.

EAA Relation to Other Accessibility Standards

The EAA builds on existing European accessibility frameworks, such as the Web Accessibility Directive (Directive 2016/2102). The Web Content Accessibility Guidelines (WCAG), particularly WCAG 2.1 Level AA, serve as a foundation for much of the digital accessibility requirements under the EAA. These guidelines ensure that web content is perceivable, operable, understandable, and robust for users with disabilities.
Additionally, for PDF documents, the EAA requires organizations to provide these in an accessible format. The correct standard for accessible PDF documents is PDF/UA (Universal Accessibility), which aligns with EAA’s accessibility goals. The PDF/UA standard ensures that PDF files are accessible to individuals using assistive technologies. It requires documents to be properly tagged so that elements like tables, images, and forms are structured for smooth navigation and easy comprehension. By following PDF/UA, you can facilitate accessibility for digital documents.

Principles of Accessibility Under the EAA

The EAA follows four key principles that mirror those in the WCAG and other accessibility regulations.

  1. Perceivability: Information must be presented to users in a way that they can perceive, regardless of their disability.
  2. Operability: Users must be able to operate the interface and all navigation elements.
  3. Understandability: The information and interface must be easy to understand, without unnecessary complexity.
  4. Robustness: Content must be robust enough to work across various platforms, devices, and assistive technologies​​.

Exceptions and Exemptions

While the EAA has broad application, there are some exceptions. Notably, microenterprises—defined as businesses with fewer than 10 employees and an annual turnover of less than €2 million—may be exempt from certain requirements. Additionally, if compliance with the EAA would impose an undue burden on a business, they may apply for an exemption, although this process can be complex and vary by member state.

EAA: Penalties for Non-Compliance

Failure to comply with the EAA can result in significant penalties that vary by country. These penalties are designed to be “effective, proportionate, and dissuasive,” and can include fines, public notices, or even suspension of services. Here’s a breakdown of fines and enforcement actions for non-compliance across all 27 EU member states.

Penalties by Country:

CountryPenalties
AustriaFines up to €200,000; repeat violations can lead to higher fines or service suspension.
BelgiumFines from €1,000 to €50,000, with possible suspension of business operations for continuous violations.
BulgariaSubstantial fines and restrictions on business operations until compliance is achieved.
CroatiaFines ranging from €2,000 to €50,000, with potential for public notices and further legal action.
CyprusFines expected between €1,000 and €20,000, with additional penalties for ongoing violations.
Czech RepublicFines up to €100,000, plus additional costs for required corrective actions.
DenmarkInitial fines set at €10,000, which increase with repeated offenses.
EstoniaFines between €5,000 and €50,000, with required corrective measures for compliance.
FinlandFines up to €150,000, with mandatory accessibility audits and documentation requirements.
FranceFines from €5,000 to €250,000, with potential public exposure for non-compliant businesses.
GermanyPenalties can reach up to €500,000, requiring corrective actions and potential suspension of services.
GreeceFines between €2,000 and €100,000, with further penalties for ongoing non-compliance
HungaryFines range from €3,000 to €50,000, with potential suspension of services for violations.
IrelandFines up to €200,000, with enforcement actions like mandatory accessibility audits.
ItalyFines range from €5,000 to €150,000, with public notices required for non-compliance.
LatviaFines up to €100,000, with corrective measures required for continued violations.
LithuaniaFines from €2,000 to €50,000, along with mandatory improvements for accessibility.
LuxembourgPenalties include fines up to €150,000 and public notices about non-compliance.
MaltaFines range from €1,000 to €50,000, with added penalties for repeat violations.
NetherlandsFines up to €250,000, with potential suspension of services for non-compliance.
PolandFines up to €200,000 and mandatory accessibility audits for non-compliant organizations.
PortugalFines between €5,000 and €100,000, with necessary corrective actions for compliance.
RomaniaFines up to €100,000, with enforcement actions for ongoing non-compliance.
SlovakiaFines between €2,000 and €50,000, with additional corrective measures required.
SloveniaFines up to €100,000, with mandatory improvements and public notices for non-compliance.
SpainFines ranging from €5,000 to €300,000, with corrective measures and possible public disclosure.
SwedenPenalties can reach up to €200,000, with required accessibility audits and corrective actions.

Compliance for EAA: What Should Businesses Do?

As the deadlines approach, businesses should take the following steps to ensure compliance:

  1. Conduct an Accessibility Audit: Assess all products and services that may fall within the EAA’s scope. This includes digital platforms, websites, apps, and physical products like kiosks or payment terminals.
  2. Implement Accessibility Best Practices: Begin making updates to ensure your products and services are compliant with WCAG 2.1 Level AA, PDF/UA, and other relevant standards. Consider automation tools that can help streamline the compliance process for high-volume document production​​.
  3. Consult Local Laws: While the EAA sets a minimum standard, some countries may implement stricter requirements. Ensure you are aware of the specific regulations in each member state where your business operates​​.
  4. Train Employees: Ensure that your team, particularly those involved in digital and product design, understand the importance of accessibility and are equipped to meet the new requirements​​.

Conclusion

The European Accessibility Act is set to reshape how businesses operate in the EU, particularly in terms of digital accessibility. With deadlines on the horizon, organizations must take steps now to ensure they are prepared. By implementing WCAG, PDF/UA, and other accessibility standards, businesses can not only avoid penalties but also contribute to a more inclusive society for individuals with disabilities.

For more information on how to ensure your digital documents are ready for June 2025, contact CDP Communications today. We specialize in helping businesses create accessible, compliant documents and ensuring that everyone can access the services they need.

The European Accessibility Act (EAA) mandates accessibility in EU products and services; it is important to pay attention to key dates, penalties, and compliance steps.

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